Privacy Policy

This policy (our “Privacy Policy” or “Policy”) explains how information about you is collected, used, and disclosed by Mass Capital Management INC (“Mass Capital Management,” “Mass Capital,” “us,” “our,” or “we”). This Privacy Policy applies to information we collect when you use masscapitalmgmt.com or any associated informational websites, electronic communications, APIs, or mobile applications (collectively, the “Mass Capital Management Site” or “Site”). We may change the Privacy Policy from time to time at our sole discretion. If we make material changes to the Policy, we will notify you by updating the “Last Updated” date at the beginning of this Policy, and adding a statement to our homepage or sending you an email notification. If you do not agree with any such modifications, your sole and exclusive remedy is to terminate your use of the Services. If you do not terminate your use of the Services, your continued access to or use of the Services will be deemed acceptance of such revised Policy.

We encourage you to review the Privacy Policy whenever you access the Mass Capital Management Site to stay informed about our information practices and the ways you can help protect your privacy. If you have any questions about this Policy, please submit your request by emailing support@masscapital-mgmt.com.

Acceptance of this Privacy Policy

By accessing and using the Mass Capital Management Site, by buying and selling digital assets with Mass Capital Management, or by using any other services that may be provided by Mass Capital Management from time to time, including, among other things, trading tools, account management tools, general news and information, trading alerts, market data including price and analytics, and educational information (collectively, the “Services”), you signify acceptance to the terms of this Privacy Policy. Where we require your consent to process your personal information, we will ask for your consent to the collection, use, and disclosure of your personal information as described further below. We may provide additional "just-in-time" disclosures or information about the data processing practices of specific Mass Capital Management Services or parts of the Mass Capital Management Site. These notices may supplement or clarify our privacy practices or provide you with additional choices about how we process your data.

If you do not agree with or are not comfortable with any aspect of this Privacy Policy, you should immediately discontinue access or use of our Services.

How we Collect Information about You

Personal information typically refers to data that identifies an individual or relates to an identifiable individual. This includes information you provide to us, information collected about you automatically, and information we obtain from third parties. The definition of personal information depends on the applicable law based on your physical location. Only the definition that applies to your physical location will apply to you under this Privacy Policy.

**Information You Provide to Us.** To establish an account and access our Services, we will ask you to provide us with some important information about yourself. This information is either required by law (e.g., to verify your identity), necessary to provide the requested Services (e.g., you will need to provide your bank account number/information to receive fiat payments in your bank account), or is relevant for certain specified purposes, described in greater detail below. As we add new features and Services, you may be asked to provide additional information. For example, if applicable, we may collect information when you create an account, provide payment information or transfer funds in and out of the account, participate in any interactive features of the Mass Capital Management Site, fill out a form, participate in a promotion, make a purchase, apply for a job, communicate with us via third-party social media sites, request customer support, or otherwise communicate with us. The types of information we may collect include your name, email address, postal address, phone number, fax number, credit card information, bank information, identity information, social security number, date of birth, digital asset address, employment information, and any other information you choose to provide.

**Information We Collect Automatically.** To the extent permitted under applicable law, we may collect certain types of information automatically whenever you interact with the Site. This information may help us address customer support issues, improve the performance of our Site and applications, provide you with a streamlined and personalized experience, and protect your account from fraud by detecting unauthorized access. Information collected automatically may include:

**Log Information.** We may log information about your use of the Mass Capital Management Site, including the type of browser you use, access times, pages viewed, your IP address, and the page you visited before navigating to the Mass Capital Management Site.

**Device Information.** We may collect information about the computer or mobile device you use to access the Mass Capital Management Site, including the hardware model, operating system and version, unique device identifiers, and mobile network information.

**Location Information.** We may collect information about the location of your device each time you access or use one of our mobile applications or otherwise consent to the collection of this information. For more details, please see “Your Privacy Rights” below.

**Information Collected by Cookies and Other Tracking Technologies.** We may use various technologies to collect information, and this may include sending “cookies” to your computer or mobile device. We may also collect information using web beacons (also known as “tracking pixels”). Web beacons are electronic images that may be used in the Mass Capital Management Site or emails and help deliver cookies, count visits, understand usage and campaign effectiveness, and determine whether an email has been opened and acted upon. For more information about cookies and how to disable them, please see “Cookie Policy” below.

**Information We Collect From Other Sources.** We may also obtain information from other sources and combine it with information we collect through the Mass Capital Management Site, as required or permitted by applicable law. For example, we may collect information about you from third parties, including, but not limited to, identity verification service providers, credit bureaus, mailing list providers, marketing service providers, advertising and analytics providers, and publicly available sources.

How We Use the Information We Collect

**Mass Capital Management Use.** We may use information about you for various reasons, including to (each of the following reasons shall be referred to as a “Reason”):

**Maintain legal and regulatory compliance.** For instance, Mass Capital Management must identify and verify customers using our Services to comply with anti-money laundering laws across jurisdictions. This may include the collection and storage of photo identification. We may use third parties to verify your identity by comparing the personal information you provide against third-party databases and public records. If you do not provide personal information required by law, we will have to close your account.

**To enforce our terms in our user agreement and other agreements.** Mass Capital Management handles sensitive information, such as your identification and financial data, so it is very important for us and our customers that we actively monitor, investigate, prevent, and mitigate any potentially prohibited or illegal activities, enforce our agreements with third parties, and/or prevent and detect violations of our posted user agreement or agreements for other Services. In addition, we may need to collect fees based on your use of our Services. We collect information about your account usage and closely monitor your interactions with our Services. We may use any of your personal information collected for these purposes. The consequences of not processing your personal information for such purposes include the termination of your account.

**To detect and prevent fraud and/or funds loss.** We process your personal information to help detect, prevent, and mitigate fraud and abuse of our services and to protect you against account compromise or funds loss.

**To provide Mass Capital Management’s Services.** We process your personal information to provide the Services to you. For example, when you want to buy or sell digital assets with us, we require certain information such as your identification, contact information, and payment information. We cannot provide you with Services without such information. Third parties, such as identity verification services, may also access and/or collect your personal information when providing identity verification and/or fraud prevention services.

**To provide Service communications.** We may send administrative or account-related information to you to keep you updated about our Services, inform you of relevant security issues or updates, or provide other transaction-related information. Without such communications, you may not be aware of important developments relating to your account that may affect how you can use our Services. You may not opt-out of receiving critical service communications, such as emails or mobile notifications sent for legal or security purposes.

**To provide customer service.** We process your personal information when you contact us to resolve any questions, disputes, collect fees, or troubleshoot problems. Without processing your personal information for such purposes, we cannot respond to your requests and ensure your uninterrupted use of the Services.

**To ensure quality control.** We may process your personal information for quality control and staff training to make sure we continue to provide you with accurate information. If we do not process personal information for quality control purposes, you may experience issues on the Services, such as inaccurate transaction records or other interruptions.

**To ensure network and information security.** We may process your personal information to enhance security, monitor and verify identity or service access, combat spam or other malware or security risks, and comply with applicable security laws and regulations. The threat landscape on the internet is constantly evolving, making it more important than ever that we have accurate and up-to-date information about your use of our Services. Without processing your personal information, we may not be able to ensure the security of our Services.

**For research and development purposes.** We may process your personal information to better understand the way you use and interact with Mass Capital Management’s Services. In addition, we use such information to customize, measure, and improve Mass Capital Management’s Services and the content and layout of our website and applications, and to develop new services. Without such processing, we cannot ensure your continued enjoyment of our Services.

**To enhance your experience.** We may process

 your personal information to provide a personalized experience and implement the preferences you request. For example, you may choose to provide us with access to certain personal information stored by third parties. Without such processing, we may not be able to ensure your continued enjoyment of part or all of our Services.

**To facilitate corporate acquisitions, mergers, or transactions.** We may process any information regarding your account and use of our Services as is necessary in the context of corporate acquisitions, mergers, or other corporate transactions. You have the option of closing your account if you do not wish to have your personal information processed for such purposes.

**To engage in marketing activities.** Based on your communication preferences, we may send you marketing communications (e.g., emails or mobile notifications) to inform you about our events or our partner events; to deliver targeted marketing; and to provide you with promotional offers. Our marketing will be conducted in accordance with your advertising marketing preferences and as permitted by applicable law.

**For any purpose.**

**Legal Bases for Processing.** Individuals located in certain jurisdictions, including the European Economic Area, have certain statutory rights in relation to their personal data. We collect and process information about you only where we have legal bases for doing so under applicable laws. The legal bases depend on the Mass Capital Management Site you use and how you use them. This means we collect and use your information in accordance with the following legal bases:

**Legitimate Interest:** when we process your personal data for our legitimate interests, we always ensure that we consider and balance any potential impact on you and your rights under data protection laws. This may form the legal basis, or part of the legal basis, for information collected pursuant to Reasons 9, 10, 11, and 12 noted above;

**Contract Performance:** on occasion, we may process information necessary for the performance of our contract with you, or to take steps at your request prior to entering into a contract. This may form the legal basis, or part of the legal basis, for information collected pursuant to Reasons 2, 4, 5, 6, and 7 noted above;

**Consent:** on occasion, in accordance with applicable laws and regulations, Mass Capital Management will obtain your freely given, specific, informed, and unambiguous consent to the processing of your personal information for one or more specified purposes. We may, if required by applicable laws and regulations, obtain your consent in order to collect information pursuant to Reasons 10, 12, and 13 noted above; or,

**Legal Obligations, the Public Interest, or in your Vital Interest:** we sometimes collect your personal information where it is necessary for compliance with applicable laws and regulations, for the performance of a task to be carried out in the public interest, or for the protection of your vital interests. This may form the legal basis, or part of the legal basis, for information collected pursuant to Reasons 1, 3, and 8 noted above.

If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, subject to any exemptions provided by law, but this will not affect any processing that has already taken place. Where we are using your information because we or a third party have a legitimate interest to do so, you may have the right to object to that use, though, in some cases, this may result in no longer being able to use the Mass Capital Management Site.

Depending on applicable laws where you reside, we may not be legally required to have legal bases for processing your personal information in accordance with this Policy. If the requirement for such legal bases does not exist under law for your operating entity or jurisdiction, Mass Capital Management has absolute discretion in ensuring your personal information is processed in accordance with the above-mentioned legal basis.

**Sharing.** We may share information about you as follows or as otherwise described in this Privacy Policy:

- With third-party identity verification services to prevent fraud. This allows Mass Capital Management to confirm your identity by comparing the information you provide us to public records and other third-party databases. These service providers may create derivative data based on your personal information that can be used in connection with the provision of identity verification and fraud prevention services.

- With financial institutions with which we may partner to process payments you have authorized.

- With service providers under contract who help with parts of our business operations. If required by laws applicable to your operating entity or jurisdiction, our contracts require these service providers to only use users’ information in connection with the services they perform for us, and prohibit them from selling users’ information to anyone else at least in all circumstances where such restrictions and prohibitions are required by applicable laws and regulations. Examples of the types of service providers we may share personal information with (other than those mentioned above) include: network infrastructure, cloud storage, payment processing, transaction monitoring, security, document repository services, customer support, internet (e.g., ISPs), data analytics, information technology, and marketing service providers.

- With companies or other entities that we plan to merge with or be acquired by. You will receive prior notice of any change in applicable policies.

- With companies or other entities that purchase Mass Capital Management assets pursuant to a court-approved sale or where we are required to share your information pursuant to insolvency law in any applicable jurisdiction.

- With our professional advisors who provide banking, legal, compliance, insurance, accounting, or other consulting services in order to complete third-party financial, technical, compliance, and legal audits of our operations or otherwise comply with our legal obligations.

- With law enforcement, officials, or other third parties when we are compelled to do so by a subpoena, court order, or similar legal procedure, or when we believe in good faith that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of our Privacy Policy or any other applicable policies.

- We may also share aggregated, anonymized information, which cannot reasonably be used to identify you. If the laws for your operating entity or jurisdiction do not prohibit the sharing of personal or pseudonymized information, Mass Capital Management has absolute discretion in ensuring any of your information that is potentially shared with third parties is anonymized.

- Mass Capital Management does not sell your personal information in its ordinary course of business and will never sell your personal information to third parties without your explicit consent unless authorized or not prohibited to do so under applicable laws.

If you establish a Mass Capital Management account indirectly on a third-party website or via a third-party application, any information that you enter on that website or application (and not directly on a Mass Capital Management website) will be shared with the owner of the third-party website or application and your information will be subject to their privacy policies.

**Online Tracking.** If permitted by applicable law, Mass Capital Management may allow others to serve advertisements on our behalf across the internet and to provide analytics services. These entities may use cookies, web beacons, and other technologies to collect information about your use of the Mass Capital Management Site and other websites, including your IP address, web browser, pages viewed, time spent on pages, links clicked, and conversion information. This information may be used by Mass Capital Management and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests in the Mass Capital Management Site and other websites, and better understand your online activity. For more information about internet-based ads, or to opt out of having your web browsing information used by certain companies for behavioral advertising purposes, please visit [http://www.networkadvertising.org](http://www.networkadvertising.org) and [http://www.aboutads.info](http://www.aboutads.info).

Security

We understand how important your privacy is, which is why Mass Capital Management maintains (and contractually requires third parties it shares your information with to maintain) appropriate physical, technical, and administrative safeguards to protect the security and confidentiality of the personal information you entrust to us to the extent required by applicable laws and regulations.

We may store and process all or part of your personal and transactional information, including certain payment information, such as your encrypted bank account and/or routing numbers, in the US and elsewhere in the world where our facilities or our service providers may be located. We protect your personal information by maintaining physical, electronic, and procedural safeguards in compliance with the applicable laws and regulations.

However, we cannot guarantee that loss, misuse, unauthorized acquisition, or alteration of your data will not occur. Please recognize that you play a vital role in protecting your own personal information. Furthermore, we cannot ensure or warrant the security or confidentiality of information you transmit to us or receive from us by internet or wireless connection, including email, phone, or SMS, since we have no way of protecting that information once it leaves and until it reaches us. If you have reason to believe that your data is no longer secure, please contact us using the contact information provided in this Privacy Policy.

Mass Capital Management reserves the right to maintain physical, technical, or administrative safeguards to protect your personal information only to the minimum extent that is required by the applicable laws of your operating entity or jurisdiction.

Retention of Personal Information

We store your personal information securely and will only retain your personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting obligations or resolving disputes. While retention requirements vary by jurisdiction, information about our typical retention practices for different aspects of your personal information are described below.

- Personal information collected to comply with our legal obligations under financial or anti-money laundering laws may be retained for as long as required under such laws.

- Where we are legally authorized to do so, contact information such as your name, email address, and telephone number for marketing purposes may be retained on an ongoing basis until you unsubscribe from receiving such materials.

- Content that you post on our website such as support desk comments, photographs, videos, and other content may

 be kept after you close your account for audit and crime prevention purposes (e.g., to prevent a known fraudulent actor from opening a new account).

- If recordings are made of our telephone calls with you, such recordings may be kept for a period of up to six years, or for however long is required or permitted by applicable laws and regulations.

- Information collected via technical means such as cookies, webpage counters, and other analytics tools is kept for a period of up to one year from the expiry of the cookie, or for however long is required or permitted by applicable laws and regulations.

Children’s Personal Information

We do not knowingly request or collect personal information from any person under the age of 18. If a user submitting personal information is suspected of being younger than 18 years of age, Mass Capital Management will require the user to close their account and will not allow the user to continue using our Services. We will also take steps to delete the information as soon as possible. Please notify us if you know of any individuals under the age of 18 using our Services so we can take action to prevent access to our Services.

Data Transferred out of the EU

We rely primarily on ‘Model Contractual Clauses’ approved by the European Commission to facilitate the international transfer of personal information collected in the EEA, the United Kingdom, and Switzerland (“European Personal Information”), and any onward transfer of such information to the extent the recipients of the European Personal Information are located in a country that the EU considers not to provide an adequate level of data protection. We may also rely on an adequacy decision of the European Commission confirming an adequate level of data protection in the jurisdiction of the party receiving the information.

Mass Capital Management is responsible for the processing of personal information it receives and subsequently transfers to a third party acting as an agent on its behalf. Before we share your information with any third party, Mass Capital Management will enter into a written agreement with the third party requiring the third party to provide at least the same level of protection for the personal information as required under applicable data protection laws.

Your Privacy Rights

Depending on applicable law where you reside, you may be able to assert certain rights related to your personal information identified below. If any of the rights listed below are not provided under law for your operating entity or jurisdiction, Mass Capital Management has absolute discretion in providing you with those rights.

Your rights to personal information are not absolute. Depending upon the applicable law, access may be denied:

- when denial of access is required or authorized by law;

- when granting access would have a negative impact on another's privacy;

- to protect our rights and properties;

- where the request is frivolous or vexatious, or for other reasons.

- **Access and Portability.** You may request that we provide you a copy of your personal information held by us. If required by applicable law, this information will be provided subject to a potential fee associated with the gathering of the information (as permitted by law), unless such provision adversely affects the rights and freedoms of others. In certain circumstances, you may request to receive your personal information in a structured, commonly used, and machine-readable format, and to have us transfer your personal information directly to another data controller.

- **Rectification of Incomplete or Inaccurate Personal Information.** You may update or correct information about you at any time by contacting support@masscapital-mgmt.com  for help. If you wish to deactivate your account, please email us at support@masscapital-mgmt.com , but note that we may retain certain information as required by law or for legitimate business purposes.

- **Erasure.** You may request to erase your personal information, subject to applicable law. If you close your Mass Capital Management account, we will mark your account in our database as "Closed," but may keep certain account information, including your request to erase, in our database for a period of time as described above. This is necessary to deter fraud, by ensuring that persons who try to commit fraud will not be able to avoid detection simply by closing their account and opening a new account, and to comply with Mass Capital Management’s legal obligations. However, if you close your account, your personal information will not be used by us for any further purposes, nor shared with third parties, except as necessary to prevent fraud and assist law enforcement, as required or permitted by law, or in accordance with this Privacy Policy.

- **Withdraw Consent.** To the extent the processing of your personal information is based on your consent, you may withdraw your consent at any time. Your withdrawal will not affect the lawfulness of Mass Capital Management’s processing based on consent before your withdrawal.

- **Restriction of Processing.** In some jurisdictions, applicable law may give you the right to restrict or object to us processing your personal information under certain circumstances. We may continue to process your personal information if it is necessary for the defense of legal claims, or for any other exceptions permitted by applicable law.

- **Automated Individual Decision-Making, Including Profiling.** Mass Capital Management may rely on automated tools to help determine whether a transaction or a customer account presents a fraud or legal risk. In some jurisdictions, you have the right not to be subject to a decision based solely on automated processing of your personal information, including profiling, which produces legal or similarly significant effects on you, save for the exceptions applicable under relevant data protection laws.

- **Cookies.** Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies, but please note that if you choose to remove or reject cookies, this could affect the availability and functionality of the Mass Capital Management Site.

- **Promotional Communications.** You may opt out of receiving promotional emails or text messages by following the instructions in those emails or text messages. If you opt out, we may still send you non-promotional communications, such as those about your account or our ongoing business relations, in accordance with applicable laws.

Cookie Policy

**What are Cookies?**

Cookies are small amounts of data that are sent to your browser and stored on your computer’s hard drive to collect standard internet log information and visitor behavior information. When you visit the Mass Capital Management Site, we can automatically collect information from you through cookies or similar technologies.

For more information, please visit: www.allaboutcookies.org.

**Why are Cookies useful?**

We may use functional cookies to analyze how visitors and clients use our website, as well as track and improve our website’s performance and function. This allows us to provide a high-quality customer experience by quickly identifying and fixing any issues that may arise. For example, we might use cookies to keep track of which website pages are most popular and which method of linking between website pages is most effective.

In addition, functional cookies, for example, may be used to allow us to remember your preferences and identify you as a user, if applicable, ensure your information is secure, and operate more reliably and efficiently. Here are some of the functions our cookies may provide us with:

- Verifying your identity and detecting the country you are currently visiting from;

- Checking browser type and device, and,

- Tracking which site the user was referred from.

**Managing Cookies**

You can delete cookies any time you want by using the settings in your web browser. You can also choose to disable cookies from your web browser, but this would mean that our website and other websites that you access may not function properly. If you do this, a potential result is that you may not be able to sign in. Further information on deleting or controlling cookies can be found at [www.aboutcookies.org](www.aboutcookies.org).

California Privacy Rights

In addition to the rights provided for above, if you are a California resident, you have the right to request information from us regarding whether we share certain categories of your personal information with third parties for the third parties' direct marketing purposes. To the extent we share your personal information in this way, you may receive the following information:

- the categories of information we disclosed to third parties for the third parties' direct marketing purposes during the preceding calendar year; and

- the names and addresses of third parties that received such information, or if the nature of their business cannot be determined from the name, then examples of the products or services marketed.

Effective January 1, 2020, pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), California residents have certain rights in relation to their personal information, subject to limited exceptions. Any terms defined in the CCPA have the same meaning when used in this California Privacy Rights section.

For personal information collected by us during the preceding 12 months that is not otherwise subject to an exception, California residents have the right to access and delete their personal information. Mass Capital Management will not discriminate against those who exercise their rights. Specifically, if you exercise your rights, we will not deny you Services, charge you different prices for Services, or provide you a different level or quality of Services.

To the extent we sell your personal information to third parties, you also have the right to request that we disclose to you: (i) the categories of your personal information that we sold, and (ii) the categories of third parties to whom your personal information was sold. You have the right to direct us not to sell your personal information. Mass Capital Management does not sell your personal information in its ordinary course of business and will never sell your personal information to third parties without your explicit consent unless authorized or not prohibited to do so under applicable laws.

If you are a California resident, you may designate an authorized agent to make a request to access or a request to delete on your behalf. We will respond to your authorized agent's request if they submit proof that they are registered with the California Secretary of State to be able to act on your behalf, or submit evidence you have provided them with power of attorney pursuant to California Probate Code section 4000 to 4465. We may deny requests from authorized agents who do not

 submit proof that they have been authorized by you to act on their behalf, or are unable to verify their identity.

How to Contact Us

If you wish to make a privacy rights request relating to your personal information, believe that we have infringed your privacy rights, or simply have any questions or concerns regarding your privacy rights or this Privacy Policy, please email us at support@masscapital-mgmt.com .